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MEMORANDUM


TO:	Steam Electric Rulemaking Record

FROM:	TJ Finseth, ERG
	Danielle Lewis, ERG

DATE:	January 28, 2013

SUBJECT:	Changes to Industry Profile for Steam Electric Generating Units for the Steam Electric Effluent Guidelines Proposed Rule


ERG is providing technical support to the U.S. Environmental Protection Agency's Office of Water, Engineering and Analysis Division (EAD) for development of effluent limitations guidelines and standards (ELGs) for the Steam Electric Power Generating Industry. EPA, with the support of ERG, distributed the Questionnaire for the Steam Electric Power Generating Effluent Guidelines (Steam Electric Survey) to 733 power plants in the summer of 2010 to gather plant-specific data on the steam electric industry. The Steam Electric Survey requested data on plant operations in 2009. EPA used the collected data to inform various analyses including, but not limited to, estimating the compliance costs and pollutant removals associated with the proposed ELGs, developing the profile of the industry, and obtaining characterization data for the wastestreams generated by the industry. EPA recognizes that plant operations and future plans regarding upgrades and modifications may have changed since the plants submitted responses to the Steam Electric Survey. This memorandum discusses changes in the operating status of steam electric generating units since 2009 and how EPA incorporated the changes into the profile developed for the industry and the costs and loadings analyses.
The principal source of information and data used in developing the proposed ELGs is the industry response to the survey distributed by EPA under the authority of section 308 of the Clean Water Act. The Steam Electric Survey obtained information on the following:
General power plant operations;
Flue gas desulfurization system operations;
Ash handling operations;
Pond/impoundment system and other wastewater treatment operations;
Metal cleaning process operations;
Pond/impoundment and landfill management practices;
Pond/impoundment and landfill leachate sampling data; and
Nuclear power operations.
The steam electric industry is a dynamic industry with frequent changes in air pollution controls and/or ash handling systems. The Steam Electric Survey requested information on plants for the 2009 operating year. EPA recognizes that there may have been changes to plant operations between 2009 and the time the survey was distributed in 2010 and additional changes that will occur by 2014, the year the ELGs are expected to be promulgated.
EPA attempted to account for these planned changes in the costs and loadings analysis, where appropriate. EPA gathered information from public sources, including company press releases and information from technology vendors, to account for the following:
Plants retiring units;
Plants converting fuel types to eliminate fossil fuel combustion residuals, especially residuals from coal or petroleum coke;
Plants upgrading a flue gas desulfurization (FGD) or leachate wastewater treatment system; and
Plants converting one or more units to a dry fly or bottom ash handling system.
Planned modifications that would result in compliance with the proposed ELGs by December 31, 2014 were excluded from the costs and loadings analysis, described in the Incremental Costs and Pollutant Removals for Proposed Effluent Limitation Guidelines and Standards for the Steam Electric Generating Point Source Category (DCN SE01964).
EPA identified 68 plants that by August 2012 had announced the retirement or fuel conversion of at least one generating unit that is scheduled to occur by December 31, 2014. Table 1 lists the name and location of plants announcing the retirement or fuel conversion of a generating unit. EPA determined that generating units would not incur incremental costs or loading reductions associated with the proposed ELGs if the unit met the following criteria:
The retirement or fuel modification had to be to complete by December 31, 2014; and
The retirement had to be substantiated by information directly from the operating company, either through an article, report, or press release.
Table 1 indicates whether the units were included or excluded in the costs and loadings analysis:
Excluded  --  Plants retiring units or converting fuels by December 31, 2014, were excluded from the analysis.
Included  --  Plants completing the modification after December 31, 2014, were included in the analysis.
Not Applicable (NA)  --  Plants were not included in the costs and loadings because they were not surveyed or do not discharge any of the wastestreams regulated by the proposed ELGs.
Included/Excluded  --  Plants listed as both included and excluded indicates that some units at the plant will be modified prior to December 31, 2014, while others will be modified after December 31, 2014. Generating units modified after December 31, 2014, were included in the costs and loadings analysis.
EPA modified the costs and loadings analysis for 30 plants based on the planned retirement or fuel conversion of at least one generating unit.
Through conversations with specific plants and vendors, as well as company press releases, EPA identified several plants that are in the process of upgrading their ash handling practices on specific generating units that will result in compliance with the proposed ELGs. EPA evaluated ash handling conversion announcements using criteria similar to those used to evaluate retirement/fuel conversion announcements. EPA determined that generating units would not incur incremental costs or loading reductions associated with certain wastestreams if the unit met the following criteria:
      1. The upgrade/modification had to be to complete by December 31, 2014, and
The upgrade had to be substantiated by information directly from the operating company, either through an article, report, or press release.
Table 2 lists the name and location of those plants excluded from the analysis due to system upgrades/modifications that EPA identified by August 2012. EPA modified the costs and loadings analysis for 11 plants due to upgrades/modifications in ash handling systems. Only the affected generating units were removed from the analysis, in some cases this resulted in the entire plant being excluded from the costs and loadings analysis.
Table 1. Plants with at Least One Generating Unit Retiring or Converting Fuels by December 31, 2014
                                  Plant Name
                                     City
                                     State
                 Included or Excluded from Costs and Loadings
                            Document Control Number
Albright Power Station
                                   Albright
                                      WV
                                   Excluded
                                    SE01261
Alma
                                     Alma
                                      WI
                                   Excluded
                                    SE02051
Altavista Power Station
                                   Altavista
                                      VA
                                      NA
                                    SE00952
Armstrong Power Station
                                    Adrian
                                      PA
                                   Excluded
                                    SE01262
Ashtabula Power Plant 
                                   Ashtabula
                                      OH
                                   Excluded
                                    SE01262
Avon Lake Power Plant 
                                   Avon Lake
                                      OH
                                   Included
                                    SE01974
B C Cobb Power Plant
                                   Muskegon
                                      MI
                                   Included
                                    SE01970
Bay Shore Plant 
                                    Oregon
                                      OH
                                   Excluded
                                    SE01262
Ben French Station
                                  Rapid City
                                      SD
                                   Excluded
                                    SE01969
Big Sandy
                                    Louisa
                                      KY
                                   Included
                                    SE01739
B L England
                                Beesleys Point
                                      NJ
                                   Included
                                    SE01824
Canadys Station
                                  Walterboro
                                      SC
                             Included/Excluded[a]
                                    SE01811
Cape Fear Steam Electric Plant
                                    Moncure
                                      NC
                                   Excluded
                                    SE01751
Cliffside Steam Station
                                   Cliffside
                                      NC
                                   Excluded
                                    SE01971
Clinch River Plant
                                   Cleveland
                                      VA
                                   Included
                                    SE01739
Conesville
                                  Conesville
                                      OH
                                      NA
                                    SE01739
Contra Costa Power Plant
                                    Antioch
                                      CA
                                      NA
                                    SE01976
Crawford Station
                                    Chicago
                                      IL
                                   Excluded
                                    SE01973
Exelon - Cromby Generating Station
                                 Phoenixville
                                      PA
                                      NA
                                    SE00954
NIPSCO D. H. Mitchell Generating Station
                                     Gary
                                      IN
                                      NA
                                    SE01334
Dunkirk Generating Plant
                                    Dunkirk
                                      NY
                                   Included
                                    SE01975
Eastlake Power Plant 
                                   Eastlake
                                      OH
                                   Excluded
                                    SE01262
Eddystone Generating Station
                                   Eddystone
                                      PA
                                   Excluded
                                    SE00951
Elrama Power Plant
                                    Elrama
                                      PA
                                   Excluded
                                    SE01974
Fisk Station
                                    Chicago
                                      IL
                                   Excluded
                                    SE01973
Gallagher Generating Station
                                  New Albany
                                      IN
                                   Excluded
                                    SE00950
Glen Lyn Plant
                                   Glen Lyn
                                      VA
                                   Included
                                    SE01739
H.B. Robinson Fossil Plant
                                  Hartsville
                                      SC
                                   Excluded
                                    SE01751
Lee Plant
                                   Goldsboro
                                      NC
                                      NA
                                    SE01746
Hopewell Power Station
                                   Hopewell
                                      VA
                                      NA
                                    SE00952
Hutsonville Power Station
                                  Hutsonville
                                      IL
                                   Excluded
                                    SE00943
JR Whiting Power Plant
                                   Luna Pier
                                      MI
                                   Included
                                    SE01970
John Sevier
                                  Rogersville
                                      TN
                                      NA
                               SE00757, SE01747
Johnsonville
                               New Johnsonville
                                      TN
                                      NA
                               SE00757, SE01749
JT Deely Steam Electric Station
                                  San Antonio
                                      TX
                                   Included
                                    SE00949
Kammer Plant
                                    Captina
                                      WV
                                   Included
                                    SE01739
Kanawha River Plant
                                    Glasgow
                                      WV
                                   Included
                                    SE01739
JC Weadock Power Plant
                                  Essexville
                                      MI
                                   Included
                                    SE01970
Lake Shore Plant
                                   Cleveland
                                      OH
                                   Excluded
                                    SE01262
L V Sutton Steam Electric Plant
                                  Wilmington
                                      NC
                                   Excluded
                                    SE01746
McMeekin Station
                                   Columbia
                                      SC
                                   Included
                                    SE01811
Meredosia Power Station
                                   Meredosia
                                      IL
                                   Excluded
                                    SE00943
Muskingum River
                                    Beverly
                                      OH
                                   Included
                                    SE01739
Neil Simpson
                                   Gillette
                                      WY
                                      NA
                                    SE01969
New Castle Power Plant
                                West Pittsburg
                                      PA
                                   Included
                                    SE01974
Niles Power Plant
                                     Niles
                                      OH
                                   Excluded
                                    SE01974
Osage Power Plant
                                     Osage
                                      WY
                                   Excluded
                               SE01740, SE01969
Philip Sporn
                                Graham Station
                                      WV
                                   Included
                                    SE01739
Picway
                                  Lockbourne
                                      OH
                                   Included
                                    SE01739
Plant Harllee Branch
                                 Milledgeville
                                      GA
                                   Excluded
                                    SE01334
Plant Mitchell
                                    Albany
                                      GA
                                   Excluded
                                    SE01334
RRI Energy Inc. Portland Generating Station
                                  Mt. Bethel
                                      PA
                                   Included
                                    SE01974
Mirant Potomac River
                                  Alexandria
                                      VA
                                      NA
                                    SE00948
R. Paul Smith Power Station
                                 Williamsport
                                      MD
                                   Excluded
                                    SE01262
Rivesville Power Station
                                  Rivesville
                                      WV
                                   Excluded
                                    SE01261
Salem Harbor Station
                                     Salem
                                      MA
                                      NA
                                    SE01742
Shawville
                                   Shawville
                                      PA
                                   Included
                                    SE01974
Southampton Power Station
                                   Franklin
                                      VA
                                      NA
                                    SE00952
State Line Energy, LLC
                                    Hammond
                                      IN
                                      NA
                                    SE01741
AEP Tanners Creek Plant
                                 Lawrenceburg
                                      IN
                                   Included
                                    SE01739
Titus Generation Station
                                   Birdsboro
                                      PA
                                   Included
                                    SE01974
Urquhart Station
                                 Beech Island
                                      SC
                                   Excluded
                                    SE01811
Waukegan Station
                                   Waukegan
                                      IL
                                   Included
                                    SE01976
Walter C Beckjord Station 
                                 New Richmond
                                      OH
                                   Included
                                    SE01743
W H Weatherspoon Steam Electric Plant
                                   Lumberton
                                      NC
                                   Excluded
                                    SE01745
Welsh
                                   Pittsburg
                                      TX
                                   Excluded
                               SE01739, SE01972
Widows Creek 
                                   Stevenson
                                      AL
                                      NA
                                    SE00757
Willow Island Power Station
                                 Willow Island
                                      WV
                                   Excluded
                                    SE01261
a  -  One of three generating units are planned to be retired by December 31, 2014.

Table 2. Plants with at Least One Generating Unit Upgrading/Modifying Ash Handling Practices by December 31, 2014
                                  Plant Name
                                     City
                                     State
                             Upgrade/Modification
                            Document Control Number
Allen Steam Plant
Memphis
                                      TN
Dry Fly Ash Conversion
SE02043, SE02044
Bull Run
Clinton
                                      TN
Dry Bottom Ash Conversion
SE02043, SE02044
Colbert
Tuscumbia
                                      AL
Dry Bottom Ash Conversion
SE02043, SE02044
Cumberland
Cumberland City
                                      TN
Dry Bottom Ash Conversion
SE02043, SE02044
Gallatin
Gallatin
                                      TN
Dry Fly Ash and Bottom Ash Conversion
SE02043, SE02044
John Sevier
Rogersville
                                      TN
Dry Bottom Ash Conversion
SE02043, SE02044
Johnsonville
New Johnsonville
                                      TN
Dry Fly Ash and Bottom Ash Conversion
SE02043, SE02044
Kingston
Harriman
                                      TN
Dry Fly Ash and Bottom Ash Conversion
SE02043, SE02044
Paradise
Drakesboro
                                      KY
Dry Fly Ash and Bottom Ash Conversion
SE02043, SE02044
Shawnee
West Paducah
                                      KY
Dry Bottom Ash Conversion
SE02043, SE02044
Widows Creek
Stevenson
                                      AL
Dry Fly Ash and Bottom Ash Conversion
SE02043, SE02044

